State v. Johnson

In State v. Johnson, 930 P.2d 358 (Wyo. 1996), the prosecution introduced co-defendant statements made during sentencing. The Court found that the statements were reliable because: (1) the declarant and the defendant were friends; (2) the declarant had no apparent reason to lie in his statements; (3) the statements were voluntary; (4) the statements were consistent over time. Johnson, 930 P.2d at 368.